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SECTION 6.0

Alternatives This section evaluates reasonable alternatives that would reduce or eliminate significant effects while attaining most of the objectives of the Huntington Beach Energy Project (HBEP) as proposed in this Application for Certification (AFC). The alternatives analyzed include the “no project” alternative, technology alternatives, water supply alternatives, and wastewater disposal alternatives. These alternatives are discussed in relation to the environmental, public policy, and business considerations involved in developing the project. The main objective of the HBEP is to produce environmentally responsible, cost effective, operationally flexible, and efficient electrical power in Southern California.

6.1 Project Objectives The key objective of the HBEP is to provide up to 939 megawatts (MW) of environmentally responsible, cost-effective, operationally flexible, and efficient generating capacity to the Los Angeles Basin Local Reliability Area in general, and specifically to the coastal area of Orange County. The project will serve local area reliability needs, southern California energy demand and provide controllable generation to allow the integration of the ever increasing contribution of variable renewable energy into the electrical grid. The project will displace older and less efficient generation in Southern California, and has been designed to start and stop very quickly and be able to quickly ramp up and down through a wide range of generating capacity. As more renewable electrical resources are brought on line as a result of electric utilities meeting California’s Renewable Portfolio Standard (RPS), projects strategically located within load centers and designed for fast starts and ramp-up and down capability, such as HBEP, will be critical in supporting local electrical reliability and grid stability.

HBEP will provide needed electric generation capacity with improved efficiency and operational flexibility to help meet southern California’s long-term electricity needs. The California Independent System Operator (CAISO) has identified a need for new power generation facilities in the Western Los Angeles Basin Local Reliability Area to replace the ocean water once-through-cooling (OTC) plants that are expected to retire as a result of the California State Water Resources Control Board’s (SWRCB) Water Quality Control Policy on the Use of Coastal and Estuarine Waters for Power Plant Cooling (OTC Policy) (CAISO, 2012a; SWRCB, 2010). The base case study results from CAISO’s year 2021 long-term Local Capacity Requirement proceeding estimates that between 2,424 and 3,834 MW of new generation is required in the Los Angeles Basin due to planned OTC retirements consistent with SWRCB OTC Policy. The requirement for new generation in light of OTC retirements in the Los Angeles Basin is also confirmed in CAISO’s Once-Through Cooling and AB-1318 Study Results presented on December 8, 2011 (CAISO, 2011). CAISO also notes that many of the OTC facilities have characteristics that support renewable integration and that repower or replacement generating capacity must retain or improve upon such capabilities (CAISO, 2012b).

The project objectives are also contingent on the use of the offset exemption contained within the South Coast Air Quality Management District’s (SCAQMD) Rule 1304(a)(2) that allows for the replacement of older, less-efficient electric utility steam boilers with specific new generation technologies on a megawatt-to-megawatt basis (that is, the replacement megawatts are equal to or less than the megawatts from the electric utility steam boilers). The offset exemption in Rule 1304(a)(2) requires the electric utility steam boiler be replaced with one of several specific technologies, including the combined-cycle configuration used by HBEP.

HBEP was designed to address the local capacity requirements within the Los Angeles Basin with the following objectives:

• Provide the most efficient, reliable, and predictable power supply available by using combined-cycle, natural-gas-fired combustion turbine technology to replace the OTC generation, support the local capacity requirements of Southern California’s Western Los Angeles Basin and be consistent with SCAQMD Rule 1304(a)(2).

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• Develop a 939-MW project that provides efficient operational flexibility with rapid-start and steep ramping capability (30 percent per minute) to allow for the efficient integration of renewable energy sources into the California electrical grid with competitive electrical generation pricing.

• Reuse existing electrical, water, wastewater, and natural gas infrastructure and land to the extent possible to minimize terrestrial resource and environmental justice impacts by developing on a brownfield site.

• Secure a sufficient-sized site to maintain existing generating capacity to meet regional grid reliability requirements during the development of HBEP.

• Site the project to serve the Western Los Angeles Basin load center without constructing new transmission facilities.

• Assist the State of California in developing increased local generation projects, thus reducing dependence on imported power.

• Site the project on property that has industrial land use designation with consistent zoning.

• Ensure potential environmental impacts can be avoided, eliminated, or mitigated to a less-than-significant level.

Locating the project on an existing power plant site avoids the need to construct new linear facilities, including gas and water supply lines, discharge lines, and transmission interconnections. This reduces potential offsite environmental impacts, and the cost of construction. The proposed HBEP site meets all project siting objectives.

The HBEP will provide power to the grid to help meet the need for electricity and to help replace dirtier, less efficient fossil fuel generation resources retired because of the use of OTC. HBEP will enhance the reliability of the state’s electrical system by providing power generation near the centers of electrical demand and providing fast response generating capacity to enable increased renewable energy development. Additionally, as demonstrated by the analyses contained in this AFC, the project would not result in any significant environmental impacts. Therefore, as will be detailed in the following sections, there are no alternatives that would be preferred over the project as proposed.

6.2 Project Overview The HBEP site is located in an industrial area of Huntington Beach at 21730 Newland Street, just north of the intersection of the Pacific Coast Highway (Highway 1) and Newland Street. The project will be located entirely within the existing Huntington Beach Generating Station, an operating power plant. The HBEP site is bounded on the west by a manufactured home/recreational vehicle park, on the north by a tank farm, on the north and east by the Huntington Beach Channel and residential areas, on the southeast by the Huntington Beach Wetland Preserve / Magnolia Marsh wetlands, and to the south and southwest by the Huntington Beach State Park and the Pacific Ocean. The site is located on a gently sloping coastal plain.

HBEP is a 939-megawatt combined-cycle power plant, consisting of two power blocks. Each power block is composed of three combustion turbines with supplemental fired heat recovery steam generators (HRSG), a steam turbine generator, an air-cooled condenser, and ancillary facilities. HBEP will reuse existing onsite potable water, natural gas, stormwater, process wastewater, and sanitary pipelines and electrical transmission facilities. No offsite linear developments are proposed as part of the project.

The project will use potable water, provided by the City of Huntington Beach, for construction and operational process and sanitary uses. During operation, stormwater and process wastewater will be discharged to a retention basin and then ultimately to the Pacific Ocean via an outfall. Sanitary wastewater will be conveyed to the Orange County Sanitation District via the existing City of Huntington Beach sewer connection. Two 230-kilovolt (kV) transmission interconnections will connect HBEP Power Blocks 1 and 2 to the existing onsite Southern California Edison (SCE) 230-kV switchyard.

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HBEP construction will require the removal of the existing Huntington Beach Generating Station Units 1, 2, and 5. Demolition of Unit 5, scheduled to occur between the fourth quarter of 2014 and the end of 2015, will provide the space for the construction of HBEP Block 1. Construction of Blocks 1 and 2 are each expected to take approximately 42 and 30 months, respectively, with Block 1 construction scheduled to occur from the first quarter of 2015 through the second quarter of 2018, and Block 2 construction scheduled to occur from the first quarter of 2018 through the second quarter of 2020. Removal/demolition of existing Huntington Beach Generating Station Units 1 and 2 is scheduled to occur from the fourth quarter of 2020 through the third quarter of 2022.

Existing Huntington Beach Generating Station Units 3 and 4 were licensed through the California Energy Commission (00-AFC-13C) and demolition of these units is authorized under that license and will proceed irrespective of the HBEP. Therefore, demolition of existing Huntington Beach Generating Station Units 3 and 4 is not part of the HBEP project definition. However, to ensure a comprehensive review of potential project impacts, the demolition of existing Huntington Beach Generating Station Units 3 and 4 is included in the cumulative impact assessment. Removal/demolition of existing Huntington Beach Generating Station Units 3 and 4 will be in advance of the construction of HBEP Block 2.

HBEP construction will require both onsite and offsite laydown and construction parking areas. Approximately 22 acres of construction laydown will be required, with approximately 6 acres at the Huntington Beach Generating Station used for a combination of laydown and construction parking, and 16 acres at the AES Alamitos Generating Station (AGS) used for construction laydown (component storage only/no assembly of components at AGS). During HBEP construction, the large components will be hauled from the construction laydown area at the AGS site to the HBEP site as they are ready for installation.

Construction worker parking for HBEP and the demolition of the existing units at the Huntington Beach Generating Station will be provided by a combination of onsite and offsite parking. A maximum of 330 parking spaces will be required during construction and demolition activities. As shown on Figure 2.3-3 in Section 2.0, Project Description, construction/demolition worker parking will be provided at the following locations:

• Approximately 1.5 acres onsite at the Huntington Beach Generating Station (approximately 130 parking stalls)

• Approximately 3 acres of existing paved/graveled parking located adjacent to HBEP across Newland Street (approximately 300 parking stalls)

• Approximately 2.5 acres of existing paved parking located at the corner of Pacific Coast Highway and Beach Boulevard (approximately 215 parking stalls)

• 225 parking stalls at the City of Huntington Beach shore parking west of the project site.

• Approximately 1.9 acres at the Plains All American Tank Farm located on Magnolia Street (approximately 170 parking stalls)

6.3 Alternatives Analysis Regulatory Requirements The Energy Facilities Siting Regulations (Title 20, California Code of Regulations [CCR], Appendix B) guidelines titled Information Requirements for an Application require:

A discussion of the range of reasonable alternatives to the project, including the no project alternative…which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and an evaluation of the comparative merits of the alternatives.

The regulations also require:

A discussion of the applicant’s site selection criteria, any alternative sites considered for the project and the reasons why the applicant chose the proposed site.

Additionally, the California Environmental Quality Act’s (CEQA) Guidelines for Implementation, Title 14, CCR, Section 15126.6(a), requires an evaluation of project alternatives based on the comparative merits of “a range of

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reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project.” The analysis must also address the “no project” alternative (CCR, Title 14, Section 15126.6 (e)). The Guidelines further state that the range of alternatives is governed by the “rule of reason,” which requires consideration only of those alternatives necessary to permit a reasoned choice and to foster informed decision making and public participation (CCR, Title 14, Section 15126.6 (f) (3)).

6.4 The No Project Alternative Under the no project alternative the existing Huntington Beach Generating Station would either employ some other means to comply with the SWQCB’s OTC Policy, such as through retrofitting the present cooling system with wet cooling technology, or be retired. Installation of wet cooling technology would be cost prohibitive based on the capital and operational costs and would further decrease the existing unit’s efficiency. Potential alternative means of complying with the SWQCB’s OTC policy are discussed in Section 6.7.2. Retiring the existing Huntington Beach Generating Station’s units without replacement generation would not be feasible based on CAISO’s 2021 projection of the need for OTC replacement generation.

In summary, the no project alternative would not serve the growing needs of Southern California and California’s businesses and residents for economical, reliable, and environmentally sound generation resources. Moreover, the no project alternative would not satisfactorily meet the project objectives specified above and thus was rejected in favor of the proposed HBEP.

6.5 Power Plant Site Alternatives Because HBEP would be located within the boundaries of an existing power plant property (AES’s Huntington Beach Generating Station) with operating power plant units, a discussion of site alternatives is not included in this AFC. Public Resources Code 25540.6 [b] reads, in part:

(b) The commission may also accept an application for a non-cogeneration project at an existing industrial site without requiring a discussion of site alternatives if the commission finds that the project has a strong relationship to the existing industrial site and that it is therefore reasonable not to analyze alternative sites for the project.

HBEP will have a strong relationship to the existing industrial site. The new facilities will provide the same service in the same location as the existing facilities, utilizing the existing City of Huntington Beach’s portable water and sanitary wastewater connections that support the existing Huntington Beach Generating Station, the SCE 230-kV switchyard and high-voltage electric transmission lines, and the existing Southern California Gas Company high-pressure, high-volume, natural gas pipelines that serves the existing facilities. The HBEP site has favorable geology and soils suitable for power plant development and has no significant engineering constraints, No new offsite development would be needed, such as upgrades or additions to the electric transmission system or natural gas pipeline system. The land use designation of the site is consistent with power plant development, and development of new facilities on the existing site would create no new significant impacts to public health of the environment.

No suitable alternative sites have been identified in the region of the proposed HBEP, which consists of densely developed residential neighborhoods, commercial facilities, and public facilities, with little suitable open land. Therefore, because HBEP will have a strong relationship to the existing industrial site, and will provide needed electric reliability service in a densely populated load pocket, and because no suitable and available alternative sites have been identified for the HBEP, no alternate sites are analyzed in this AFC, and only the proposed site for HBEP is discussed below. Furthermore, if a suitable brownfield site were identified, it is unlikely that such a site would provide the necessary infrastructure already available at the proposed HBEP site. Therefore, an alternative site will likely not reduce or avoid any impacts associated with the proposed HBEP site, which, as the analysis in this AFC shows, are already below significant levels. Further, development on alternative sites could result in greater impacts than present with development of the proposed site.

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6.5.1 Proposed Project Site The proposed site for HBEP is located within the existing Huntington Beach Generating Station site located at 21730 Newland Street, at its intersection with the Pacific Coast Highway, in Huntington Beach, California. The existing site is shown in Figure 6.5-1. The existing site consists of four natural-gas-fired electric utility steam generating units on the western border of the property closest to the ocean. To the north and east of the operating units are seven large tanks formerly used to store supplies of fuel oil prior to the elimination to the use of fuel oil for the Huntington Beach Generating Station generation units. Two of the existing tanks on the northeast portion of the existing Huntington Beach Generating Station would be demolished and replaced with the new HBEP power plant facilities. The existing Huntington Beach Generating Stations is designated and zoned as Public/Semipublic, which allows construction and operation of “Generating plants, electrical substations, above-ground electrical transmission lines, switching buildings, refuse collection, transfer, recycling or disposal facilities” (City of Huntington Beach, 2010).

The site meets all of the project’s objectives and would have no significant, unmitigated, environmental impacts. The HBEP site:

• Is located adjacent to a high-pressure natural gas supply pipeline

• Is located adjacent to an existing high-voltage switchyard

• Is located near the centers of electrical demand within the Western Los Angeles Basin Local Reliability Area for maximum efficiency and system benefit

• Minimizes construction impacts on existing residences and businesses

• Has feasible mitigation of potential environmental impacts

6.5.2 Summary and Comparison Based on the following site selection criteria, it is clear the siting of a power plant is feasible at the proposed site. Following is a summary of site selection factors:

• Site control feasible – Site control has been achieved at the HBEP site, as it would be located within the boundaries of the existing Huntington Beach Generating Station owned by AES.

• Located on a brownfield site – The new HBEP facilities would be located within an existing industrial facility on the site of two existing storage tanks and electrical generating units (existing Huntington Beach Generating Station’s Units 1 and 2) that will be demolished as part of the project.

• Location near electrical transmission facilities – The HBEP site is already served by high-voltage transmission lines connecting the facility to the SCE electrical transmission grid through an existing SCE 230-kV switchyard located within the boundaries of the existing Huntington Beach Generating Station.

• Location near ample natural gas supply – the existing Huntington Beach Generating Station is presently served by a high-pressure, high-volume, 16-inch, natural gas pipeline owned by the Southern California Gas Company.

• Land zoned for industrial use – The site is designed and zoned Public/Semipublic by the City of Huntington Beach General Plan and zoning code, which allows construction and operation of major utility projects, including power plants and substations/switchyards.

• Parcel or adjoining parcels of sufficient size for the site – The HBEP site is adequately sized to allow for both the project site and construction.

• Location near the centers of electrical demand – The site is located in western Orange County, where electrical demand is high due to dense development of residential, commercial, and industrial facilities, and construction of new transmission line projects to import power into the region is difficult due to the lack of open space. In addition, because of the dense residential, commercial and industrial density in the region, there is also the lack of space for a development of a new power generating facility of the size of HBEP.

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• Location in a local reliability area – The site is located in an area of local reliability need identified by the CAISO that cannot be served by any other existing or proposed generating station.

• Minimizes impacts on local residents and businesses – HBEP is located in an existing industrial area, on a site that has continuously been operated as a power plant for more than 50 years. Noise and visual impacts at the site would be similar or lower than what is already part of the baseline environment.

• Mitigation of potential impacts is feasible – As documented in this AFC, mitigation of potentially significant environmental impacts from the HBEP to less than significant is feasible

When taking into account all factors above, the HBEP site meets all project objectives. The HBEP site has a known adjacent supply of natural gas and water, a connection to an existing sanitary sewer, and an existing electric transmission interconnection onsite. The HBEP site is zoned appropriately for power plant uses and would be located in an industrial area near existing industrial facilities. Further, the HBEP site meets the project’s objectives without resulting in any adverse environmental impacts.

6.6 Alternative Project Design Features This section addresses alternatives to some of the HBEP design features, such as the locations of the natural gas supply pipeline, electrical transmission interconnection, and water supply pipeline.

6.6.1 Alternative Natural Gas Supply Pipeline Routes HBEP will connect to the existing onsite high-pressure natural-gas pipeline; therefore, no other alternatives were analyzed.

6.6.2 Electrical Transmission System Alternatives HBEP will connect to the existing onsite electric switchyard, which connects the existing facilities to the SCE electrical system; therefore, no other alternatives were analyzed.

6.6.3 Water Supply Alternatives HBEP will use air-cooled condensers (dry cooling) to supply plant cooling, rather than the once-through seawater cooling system used for the existing Huntington Beach Generating System. An air-cooled plant typically uses less than 7 percent of the total water use of a comparable wet-cooled plant. Fresh water demand at HBEP will be limited to onsite potable water use, makeup water for the new generating units’ steam cycle, and for cooling of the air intake into the combustion turbine generator. The total potable water demand for HBEP would never exceed more than 115 acre-feet per year, which is the equivalent to the use of about 583 average four-person families in the U.S., based on average per capita use of 84,387 gallons per year per family (Rockaway, 2011) but would provide electricity for more than 1 million homes. Furthermore, this annual water use is approximately 48 percent lower than historical use by the existing Huntington Beach Generating Station Units 1 through 4 of 290 acre-feet per year (2004 to 2011).

Potential water supply sources for the HBEP include seawater from the Pacific Ocean, potable water from the City of Huntington Beach municipal water system, tertiary treated wastewater through the Green Acres reclaimed water program operated by the Orange County Sanitation District (OCSD) and Orange County Water District (OCWD), and secondary treated wastewater from the OCWD’s Huntington Beach Wastewater Treatment Facility, located adjacent to the mouth of the Santa Ana River approximately 1.5 miles east of the HBEP. Seawater could be used as makeup water for a saltwater cooling system, or could be desalinated to be used as fresh water. Use of ocean water in a seawater cooling tower system is discussed in Section 6.7.2, Power Plant Cooling Alternatives.

Southern CaliforniaEdison 230kV Switchyard

AES Huntington BeachEnergy Project

Onsite Construction Parking

LegendAES Huntington Beach Generating StationAES Huntington Beach Energy ProjectOnsite Construction Parking

AES Huntington Beach Energy ProjectCity of Huntington BeachSouthern California Edison

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FIGURE 6.5-1Site Location MapAES Huntington Beach Energy ProjectHuntington Beach, California

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Using tertiary treated reclaimed water under the Green Acres program would require construction of a pipeline from the HBEP site to the nearest available connection to the Green Acres reclaimed water pipeline system, located just south of the Mesa Verde Country Club golf course near where Adams Avenue crosses over the Santa Ana River. The pipeline would likely be located under city streets, requiring construction of approximately 3.7 miles of new pipeline. However, according to the OCWD, the Green Acres program is already nearly fully subscribed, and remaining capacity will be used for the County’s groundwater recharge program (Steinbergs, 2011). Therefore, tertiary treated wastewater from the Green Acres program is not a viable source of makeup water for the HBEP.

Use of secondary treated wastewater from the OCSD’s Huntington Beach treatment facility would require construction of a treatment facility either at the OCSD site or at the HBEP site to further treat the wastewater to the standards required for power plant use, as well as storage facilities to ensure sufficient treated water is on hand at all times, and an approximately 1.5-mile-long pipeline connecting the two facilities. Construction and operation of the tertiary treatment facility and the 1.5-mile pipeline would create their own environmental impacts, including those associated with disposal of the waste products created during the treatment process. Cost of constructing the additional treatment facilities is estimated at $1.5 million to $2 million, and cost of constructing the pipeline is estimated at $1 million to $1.6 million, assuming a suitable right-of-way could be obtained. Both the treatment and conveyance estimates were made for planning and comparison purposes only, based on known costs of conventional mono-media sand filtration and sodium hypochlorite disinfection, as well as typical urban water pipeline engineering, permitting, procurement and construction costs. The estimates did not include detailed investigations of permitting, exact locations of treatment facilities, interference with existing utilities, nor jurisdictional agreements for the preliminary pipeline routes.

Desalinated water is also a possible source of freshwater for the HBEP. Poseidon Resources LLC is developing the Huntington Beach Seawater Desalination Project to be located adjacent to the HBEP. The proposed Poseidon project would produce up to 50 million gallons per day (56,000 acre-feet per year) of potable water to coastal and south Orange County, meeting approximately 8 percent of total demand in the region. The project has received approval from the City of Huntington Beach, the California State Lands Commission, and the Santa Ana Regional Water Quality Control Board (RWQCB), but as of June 2012 had not yet obtained approval from the California Coastal Commission (not yet scheduled). The desalination project would use approximately 35 MW of power during operations. Water from the facility would be delivered to the Metropolitan Water District of Southern California (MWD) main system, and then distributed to 10 nearby cities or water districts, including the City of Huntington Beach. If the Poseidon project is ultimately approved and constructed, the facility could provide water directly to the HBEP, or augment other supplies through the MWD and City of Huntington Beach systems (City of Huntington Beach, 2005). Reliance on the Poseidon desalination plant as the sole source of water for the HBEP could restrict operations of the HBEP during times the desalination plant is not operating, and could greatly increase the cost of water use, as potable water supplies from the Poseidon desalination plant are projected to cost approximately double that from existing sources. The Poseidon desalination plant also has yet to receive all needed approvals to begin construction, and even if all approvals are received, there is no guarantee the plant would be built in time for HBEP use, or at all. Therefore, use of desalinated water as an augmentation of regular potable water sources is not preferred due not only for water supply reliability reasons, but also because of cost.

The SWRCB’s Water Quality Control Policy on the Use and Disposal of Inland Waters Used for Powerplant Cooling states the use of fresh water for cooling purposes by power plants should only be allowed where alternative water supply sources and alternative cooling technologies are shown to be environmentally undesirable or economically unsound. Use of the City of Huntington Beach’s potable water system is both economically feasible and environmentally desirable. Potable water is available onsite in sufficient quantities to supply all freshwater needs, and avoids the need to construct pipelines or additional treatment facilities for the use of secondary treated wastewater. The City serves approximately 52,000 customers through 590 miles of distribution pipeline. The City receives approximately 65 percent of its water from local groundwater wells, and approximately 35 percent from the MWD, which in turn obtains water from the Colorado River and the State Water Project.

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The City is currently capable of pumping up to 30,000 gallons per minute (gpm) from 10 wells varying in depth from 250 to 1,020 feet deep. The City can also obtain up to 25,000 gpm from its three connections to the MWD system, and can obtain up to 44,365 gpm of supply from its own system of four reservoirs and booster stations. Total available freshwater supply to the City was 41,440 acre-feet in 2010, and total use was 29,468 acre-feet, leaving a surplus availability of approximately 11,972 acre-feet in that year. With planned system expansion, supply is projected to be 45,000 acre-feet in 2015, then increase approximately 900 acre-feet per year to a peak of about 54,240 acre-feet in 2025 before declining to 53,090 acre-feet in 2030, and 51,090 acre-feet in 2035. Total demand in the City is projected to be nearly flat over the forecast period, increasing from approximately 32,260 acre-feet in 2015 to about 34,660 acre-feet in 2035. The city is projected to have a surplus in supply, of between 2,570 (multiple dry years) and 20,400 acre-feet (normal years) over the planning period to 2035 (City of Huntington Beach, 2011).

At a projected maximum use of 115 acre-feet per year, HBEP fresh water use would amount to less than 0.8 percent of total projected freshwater deliveries in the City in 2015, and less than 10 percent of the lowest projected available surplus of water supply in the City, in multiple dry years. These estimates do not reflect HBEP’s overall net reduction in water consumption over the historical water use by the existing Huntington Beach Generating Station’s operation. Service through the City’s water system would require no new construction of facilities to meet the HBEP’s demand. Therefore, because other sources would create additional environmental impacts and be more costly, use of the City’s potable water system is the preferred source of water for the HBEP.

6.7 Technology Alternatives The HBEP configuration was selected from a wide array of technology alternatives. These include generation technology alternatives, fuel technology alternatives, combustion turbine alternatives, storage alternatives, and nitrogen oxide (NOx) control alternatives.

6.7.1 Generation Technology Alternatives Selection of the power generation technology focused on those technologies that can utilize the natural gas readily available from the existing gas pipeline system, and meet the requirements for exemption under SCAQMD’s Rule 1304, which specifies that technology replacing existing utility steam boilers, must be combined-cycle technology or other use of advanced turbine technology, or a renewable energy resource, and meet the project’s objectives. Following is a discussion of the suitability of such technologies for application to the HBEP that were rejected for failing to meet HBEP’s project objectives for the reasons described below.

6.7.1.1 Conventional Boiler and Steam Turbine This technology burns fuel in the furnace of a conventional boiler to create steam. The steam is used to drive a steam turbine generator, and the steam is then condensed and returned to the boiler. This technology that can achieve thermal efficiencies up to approximately 36 percent when utilizing natural gas, although efficiencies are somewhat higher when utilizing oil or coal. Several conventional boiler/steam turbine technologies were reviewed but rejected due to regulatory prohibitions or public acceptance. Specifically, the technologies rejected were nuclear and municipal solid waste generation.

Because of this technology’s low efficiency and large space requirement, and because it would not meet the requirements for exemption under SCAQMD Rule 1304, conventional boiler and steam turbine technology was eliminated from consideration.

6.7.1.2 Simple-Cycle Combustion Turbine Aero-derivative turbine-generator units are able to achieve thermal efficiencies up to approximately 38 percent. A simple-cycle combustion turbine has a quick startup capability and comparable capital cost to that of a combined-cycle, and is appropriate for peaking applications. However, simple-cycle combustion turbines have lower thermal efficiency and emit more air pollutants per kilowatt hour (kWh). Because of this relatively low efficiency, and because it would not meet the requirements for exemption under SCAQMD Rule 1304, simple-cycle combustion turbine technology was eliminated from consideration.

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6.7.1.3 Kalina Combined-Cycle This technology is similar to the conventional combined-cycle, except a mixture of ammonia and water is used in place of pure water in the steam cycle. The Kalina cycle could potentially increase combined-cycle thermal efficiencies by several percentage points. This technology is still in the development phase and has not been commercially demonstrated; therefore, it was eliminated from consideration.

6.7.1.4 Internal Combustion Engines

Internal combustion engine designs are also available for small peaking power plant configurations. These are based on the design for large marine diesel engines, fitted to burn natural gas. Advantages of internal combustion engines are that they use very little water for cooling because they use a closed-loop coolant system with radiators and fans; provide quick-start capability (online at full power in 10 minutes); and are responsive to load-following needs because they are deployed in small units (for example, 10 to 14 engines in one power plant) that can be started up and shut down at will. Disadvantages of this design include higher emissions than comparable combustion turbine technology. Additionally, an internal combustion engine installation is generally deployed at less than 150 MW and so would not meet the project objective to generate 980 MW of power and was eliminated from consideration.

6.7.2 Power Plant Cooling Alternatives Wet cooling technology was evaluated as an alternative to the use of an air-cooled condenser system for the HBEP, using either freshwater or seawater as the water makeup source. With a wet-cooled plant, water is pumped through a condenser, where it is exposed to pipes carrying steam from a steam turbine. The steam condenses to water and is recycled through the HRSG. Heated water cycling through the condenser is then pumped to a cooling tower, where large fans draw air through the heated water droplets, cooling the water, which is cycled back to the condenser, with evaporative losses of approximately 5 percent.

Wet cooling using fresh or potable water is discouraged by the SWRCB and CEC policy. Wet cooling using recycled water is acceptable under state policy, but the choice of this cooling method depends on the availability of a supply of tertiary treated recycled water. Such recycled water is not currently available at the HBEP site. As discussed in Section 6.6.3, tertiary treated water is available approximately 3.5 miles from the HBEP site, but not in sufficient quantities to supply project needs. Secondary treated water is available at the OCSD’s Huntington Beach treatment facility and could be used as a possible source of cooling water makeup, though doing so would require construction of a 1.5-mile-long pipeline and additional facilities to treat the wastewater to the standards required for power plant use. Wet cooling using seawater in the cooling towers is another possibility, though this method would require taking suction off of an ocean intake structure for makeup supplies, which would create project-related environmental impacts. Maintenance and operating costs for a cooling tower system using seawater are also significantly higher than for systems using freshwater. The use of seawater as cooling tower makeup water typically imposes a 4 to 8 percent performance penalty and a 35 to 50 percent cost penalty in comparison to freshwater towers of comparable cooling capability (Maulbetsch and DiFilippo, 2010).

The major drawback of wet cooling is that it takes large amounts of water to cool a large, combined-cycle power plant: approximately 16 times as much as a dry-cooled design. Therefore, because of the uncertainty in obtaining reliable and cost-effective water supply in sufficient quantities to allow use of wet cooling, HBEP has been designed as a dry-cooled plant using an air-cooled condenser. No other technologies are currently available that are capable of adequately cooling the HBEP.

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6.7.3 Fuel Technology Alternatives Technologies based on fuels other than natural gas were eliminated from consideration because they do not meet the HBEP’s project objective of utilizing natural gas available from the existing gas piping system. Additional factors rendering alternative fuel technologies unsuitable for the HBEP are as follows:

• No geothermal or hydroelectric resources exist in Orange County.

• Biomass fuels such as wood waste are not locally available in sufficient quantities to make them a practical alternative fuel, and HBEP site space is limited.

• The HBEP site does not experience sufficient wind resources to make a wind project feasible at the site. Additionally, wind technologies are not flexible and dispatchable resources because of their variable nature. Also, HBEP space is limited and these technologies require large expanses of land, and a wind power installation would not be compatible with surrounding land uses. While wind technologies are commercially available, due to the unavailability of sites in or near the Western Los Angeles Basin Local Reliability Area (excluding offshore sites), limited dependability, and relatively higher costs, wind technologies were eliminated from consideration.

• Utility-scale solar technologies need to be sited in an area with high solar radiation1

• The availability of the natural gas resource provided by Southern California Gas Company and the environmental and operational advantages of natural gas technologies make natural gas the logical choice for the HBEP.

and require very large amounts of land (up to 10 acres per megawatt). Orange County is not a viable location for concentrating solar technologies or utility-scale photovoltaic power plants because it is lacking in the large and open expanses of land necessary and is not a strong solar energy resource area. These resources are also available only during the daytime and may have reduced availability on cloudy days.

6.7.4 NOx Control Alternatives To minimize NOx emissions from the HBEP, the combustion turbine generators will be equipped with dry low NOx combustors and selective catalytic reduction (SCR) using 19 percent aqueous ammonia as the reducing agent. The following combustion turbine NOx control alternatives were considered:

• Steam injection (capable of 25 parts per million [ppm] NOx) • Water injection (capable of 25 ppm NOx) • Dry low NOx combustors (capable of 9 to 25 ppm NOx)

Dry low NOx combustors were selected because these allow for lower NOx emission rate from the combustion turbine over either water or steam (wet) injection. Furthermore, dry low NOx combustors result in a slight improvement in thermal efficiency over wet injection NOx control alternatives, and reduces the HBEP’s water consumption.

Two post-combustion NOx control alternatives were considered:

• SCR • SCONOx

SCR is a proven technology and is commonly used in combustion turbine electrical generating applications. Ammonia is injected into the exhaust gas upstream of a catalyst. The ammonia reacts with NOx in the presence of the catalyst to form nitrogen and water.

SCONOx consists of an oxidation catalyst, which oxidizes carbon monoxide to carbon dioxide and nitric oxide to nitrogen dioxide. The nitrogen dioxide is adsorbed onto the catalyst, and the catalyst is periodically regenerated.

1 Measured in terms of kilowatt-hour per square meter of land. See the National Renewable Energy Laboratory for additional information about solar energy and maps of solar resource distribution (http://www.nrel.gov/solar/). The project area solar radiation is rated at approximately 5 to 5.25 kWh per square meter. Utility-scale solar energy plants are not currently being proposed for areas with solar radiation at levels this low.

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The level of emission control effectiveness between the SCONOx and SCR technologies is approximately equivalent. However, the SCONOx technology does not use ammonia to reduce air emissions. The CEC recently summarized in the U.S. Environmental Protection Agency’s opinion (CEC, 2007) “that SCONOx is no more effective for reducing air quality impacts than selective catalytic reduction…, and it also found SCONOx to be significantly more expensive and arguably less reliable, particularly for larger facilities.” Therefore, SCONOx was not considered for the HBEP.

The following reducing agent alternatives were considered for use with the SCR system:

• Anhydrous ammonia • Aqueous ammonia • Urea conversion

Anhydrous ammonia is used in many combustion turbine facilities for NOx control, but is more hazardous than diluted forms of ammonia. Aqueous ammonia (an ammonia-water solution) is proposed for the HBEP because of its safety characteristics.

Urea conversion technology uses solid urea (prill) in a reactor with steam to convert the urea to aqueous ammonia. The aqueous ammonia is typically stored in a tank for use by the SCR system during upsets in the process and during plant start up activities. The existing Huntington Beach Generating Station’s generating units use a urea conversion process installed in 2002. Although the urea conversion technology has been employed on the Huntington Beach Generating Station for a number of years, it only eliminates the need to truck aqueous ammonia to the site, as onsite ammonia storage is included in the system design. Furthermore, the urea conversion process has a higher energy demand over an aqueous ammonia system as a result of consuming steam as part of the process. Finally, the urea process has proven to have poor reliability and slow response times, and it produces an inconsistent concentration of ammonia. The HBEP power blocks are designed to be fast-start and fast-ramp units, which require precise control of ammonia concentrations for emissions control. Therefore, urea conversion was considered and rejected for the HBEP.

6.7.5 Energy Storage Energy storage options currently available include electrochemical energy storage, thermal energy storage, hydrogen production, and mechanical energy storage. Electrochemical storage includes several types of batteries and capacitors which meet specific needs and requirements in certain application; however, to date, these energy technologies would not be able to meet the project’s objectives of providing 939 MW for an extended period of time to meet local grid reliability requirements. Furthermore, an energy storage project capable of 939 MW is not feasible within the proposed footprint.

Thermal energy storage primarily is limited generally to heat energy storage from solar thermal applications for later use, such as steam for power production during evening hours, or for water or building heating purposes, and therefore would not meet the HBEP objectives. Hydrogen production involves “storing” energy by using inexpensive or surplus energy (for example, off-peak energy from all sources, or surges of windpower during the night) to create hydrogen through hydrolysis, and then use the hydrogen to create energy for other purposes, including on-peak generation, as well as transportation purposes. However, hydrogen production has not yet been demonstrated as a cost-effective alternative to generation services that the HBEP would provide.

Compressed air technology also stores energy by using inexpensive or surplus electrical energy to operate compressors that store high-pressure air for later release through an air-powered turbine, while flywheel technology utilizes off-peak power to accelerate large rotors (flywheels) to very high speeds, and then use the energy stored as angular momentum to spin a generator during on-peak power periods. While promising, compressed air and flywheel technology have not yet been demonstrated to be cost-effective methods for storing energy on a large scale.

The only utility-scale energy storage technology currently in use in California is pumped-storage hydroelectricity, in which energy is stored by pumping water from a lower reservoir to a higher reservoir when inexpensive or surplus energy is available, and then released through a turbine-generator when additional generating capacity

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and energy is needed. These projects require two reservoirs at significantly different elevations, plus a pumping/generating station and connecting penstock, and therefore have very specific siting requirements not generally found in the population centers of the greater Los Angeles Basin (CEC, 2011). Because of the very limited ability to site cost-effective energy storage facilities that are able to provide reliable electric power services to the Western Los Angeles Basin, energy storage technologies were considered but rejected for the HBEP.

6.7.6 Waste Discharge Alternatives The HBEP will discharge process wastewaters through the existing Huntington Beach Generating Station’s ocean outfall, consistent with the way process wastewater is discharged currently from the Huntington Beach Generating Station. Similar to the existing Huntington Beach Generating Station, stormwater from HBEP will be processed through an oil/water separator as necessary, and through the existing stormwater retention basin located onsite and then discharged through the existing Huntington Beach Generating Station’s ocean outfall. AES met with the staff of the Santa Ana RWQCB on March 20, 2012, to discuss the discharge of HBEP process wastewater and the continued discharge of stormwater from HBEP through the existing Huntington Beach Generating Station’s ocean outfall (see Appendix 5.15D for Meeting Memorandum for the Record). At this meeting, the RWQCB staff representative concurred with the approach for the continuation of discharging the process wastewater and site stormwater from HBEP through the existing outfall, providing the project obtains a new National Pollutant Discharge Elimination (NPDES) Permit and the discharge meets all ocean standards. As part of the design of the HBEP, the current requirements of Orange County for stormwater drainage design and discharges will be achieved (see Section 5.15, Water Resources).

The alternative discharge method for process wastewater would be to construct a zero liquid discharge (ZLD) system in which concentrators and crystallizers are used to evaporate process wastewater and to remove the residual salts and other contaminants such that little or no water is discharged, and residual salt is trucked as a “salt cake” byproduct to a landfill. The CEC, as stated in the 2003 Integrated Energy Policy Report (IEPR), has encouraged power plant developers to incorporate ZLD facilities into their power plant designs as a way of reducing discharges and maintaining the quality of state waters. The 2003 IEPR states:

Additionally, as a way to reduce the use of fresh water and to avoid discharges in keeping with the Board’s policy, the Energy Commission will require zero-liquid discharge technologies unless such technologies are shown to be “environmentally undesirable” or “economically unsound.”

The use of a ZLD design was considered for the HBEP and was eliminated from consideration for the following reasons:

• It is not necessary to use a ZLD to control wastewater discharge in a plant using dry cooling, because discharge volumes using dry cooling are relatively small, approximately one-sixteenth those of a wet-cooled plant.

• ZLD systems are technologically complex and expensive to construct, operate, and maintain, adding to the project’s capital cost and reducing its return on investment.

• ZLD systems have been found to be relatively unreliable, often resulting in plant outages that affect operating ability, the availability of power, and grid reliability.

To summarize, using ZLD for a dry-cooled plant of this nature would not support the HBEP objectives of providing easily dispatchable, reliable, and economically viable power to the northern California grid. The cost of a ZLD in terms of initial construction costs, operations and maintenance costs, and lost production costs would be out of proportion to any environmental benefits of eliminating the very low volume of wastewater expected to be generated by the HBEP. The use of a ZLD would be economically unfeasible and would offer little or no environmental benefit.

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6.8 References California Energy Commission (CEC). 2007. Final Staff Assessment for the Colusa Generating Station Power Plant. November.

California Energy Commission (CEC). 2011. Public Interest Energy Research (PIER) Program Final Project Report, 2020 Strategic Analysis of Energy Storage in California. Publication Number CEC-500-2011-047. November.

California Independent System Operator (CAISO).2011. Once-Through Cooling & AB1318 Study Results. December 8.

California Independent System Operator (CAISO).2012a. 2011-2012 Transmission Plan. March 23.

California Independent System Operator (CAISO).2012b. 2012/2013 Transmission Planning Process Unified Planning Assumptions and Study Plan. March 30.

City of Huntington Beach. 2005. Draft Recirculated Environmental Impact Report, Seawater Desalination Project at Huntington Beach. April 5.

City of Huntington Beach. 2010. Huntington Beach Zoning and Subdivision Ordinance Chapter 204. February 10.

City of Huntington Beach. 2011. 2010 Urban Water Management Plan. June 20.

Maulbetsch, John S., and Michael N. DiFilippo. 2010. Performance, Cost, and Environmental Effects of Saltwater Cooling Towers. California Energy Commission, PIER Energy-Related Environmental Research Program, Publication No. CEC-500-2008-043. January.

Rockaway, Thomas D., et al. 2011. Residential Water Use Trends in North America. Journal of the American Water Works Association. February.

State Water Resources Control Board (SWRCB). 2010. Statewide Water Quality Control Policy on the Use of Coastal and Estuarine Waters for Power Plant Cooling. October 1.

Steinbergs, Chuck, Principal Engineer / Orange County Water District. 2011. Personal Communication with Matt Trask/CH2M HILL. December 27.